MORE ON DIOXINS

Yesterday I wrote here about the myths and fallacies involved in alleging that even the most toxic to mankind chemicals have "safe" exposure limits. I would agree that they are "safe" to the toxicologist writing the report as well as to the lab person (following appropriate safety protocols) testing animals etc. Not so much however to the human beings who already have a lifetime of exposures to contaminated air, food and water even though allegedly each and every separate exposure may or may not be below so called "safe" levels. Today I'm going to mention a little about dioxin levels in soil. ............................................................................................................................. Background levels are badly abused. Here in Elmira, Uniroyal/Crompton/Chemtura and Lanxess have all been using "background" concentrations immediately upstream from the infamous polluter. Hence ongoing discharges from the Bolender Park Landfill plus one or two further upstream polluters are affecting upwards the contaminant concentration levels in the Canagagigue Creek. Hence the company (Lanxess) can hide somewhat behind those higher background levels. The 1987 U.S. EPA National Dioxin Study suggested that background be defined as "an area where you would not expect to find any dioxin.". The Centre for Health, Environment and Justice in 1998 suggested that the national background estimate for dioxin by the EPA of 8 parts per trillion (ppt) was far too high as it encompassed a number of known source areas of dioxins. They suggested that 1 ppt was far more appropriate. Overall the studies showed as expected that rural areas had far lower dioxin levels than urban ereas which were far closer to dioxin sources. Here in Elmira we can't even get our corrupt Ontario Ministry of Environment to honestly and seriously sample soils to the immediate east side of the Lanxess site (i.e. Stroh farm). ........................................................................................................................................... One study in 2010 suggested dioxin action levels of 240 ng/kg (ppt) for residential areas. They also suggested that more soil samples were far better than fewer which has been ignored in Elmira. Also ignored here in Elmira was the suggestion that heavy dioxin contaminated soils should all be remediated versus reliance on purely risk-based action levels. I view that a an anti-Risk Assessment position. ...................................................................................................................... In 2012 the EPA released an assessment of dioxins suggesting that the threshold for "safe" dioxin exposure was a TEQ (toxic equivalency) of .7 picograms per kilogram of body weight per day. The U.S. Chemical Industry were not happy with that and the American Chemical Councill (ACC) suggested that it was unclear to them why the EPA set a dioxin exposure level that is three times more stringent than other countries and the World Health Organization (WHO). .................................................................................................................................... Regarding soil background levels the U.K. study in 2009 suggested that soil dioxin levels were consistently higher in the urban areas than in the rural areas. This included dioxin-like PCBs. Rural soils for the various dioxin compounds were between .17 ppt and 60.7 ppt. Urban soils for the various dioxin compounds ranged from .35 ppt to 104 ppt. .................................................................................................................................................. Back in 2004 the U.S. discussed retaining the 50 ppt (TEQ) soil screening level. Compare this to current Canadaian criteria of 7 and 13 parts per trillion (ppt) for dioxins (TEQ) in soils. The 7 ppt is for soils within 30 metres of a surface water body and the 13 ppt for soils further away. There was also discussion of some of the non-cancer health effects of dioxins including hormonal impacts of endocrine disrupters such as dioxins. Other effects included a causal effect in adult-onset diabetes from dioxin exposure. ................................................................................................................................................ Permitting allegedly low concentrations of highly toxic chemicals is a mugs game. Pretending to only need to remediate the very highest concentrations of dioxins is simply to keep the population calm and quiet. If they knew how badly they and their families health was compromised by industrial releases past and present, political heads at the least would roll.

ONGOING DIOXIN STUDIES

The literature on-line can be overwhelming. It can sometimes be contradictory, other times reasonably consistent in their findings. Problems exist in calculating toxicities of various chemicals because among other things while it is legal (moral???) to inject animals with toxins and observe the results, generally speaking human testing has been universally frowned upon. I've long had a problem with Risk Assessments because they attempt to mathematically "prove" that which is impossible to prove. While human beings around the world are remarkably similar biologically, their environments, living conditions and exposures to toxins are incredibly diverse. Literally one human being could be dosed accidentally with dioxins and walk away apparently unscathed while another with different background past exposures combined with different genetics could require immediate hospitalization and intensive care. There is also the issue of longterm effects. Dosing either accidentally or intentionally today may give apparent zero health effects yet the individual twenty-five years down the road may suddenly develop cancer (or other serious disease) with no obvious additional toxic exposures. It is all very difficult to mathematically determine safe levels, action levels etc. especially when those levels are based upon study of that one chemical/toxin at a time. The reality is that all toxins are in conjunction with other factors including past exposures, future exposures, different toxins, different diets, heat, humidity, type of exposure (eg. inhalation, ingestion, dermal etc.). In other words one size (criteria) does not fit all human beings nor does it fit any single human being throughout their life span. A strong and healthy female in her mid twenties does not have the identical immune system, metabolism etc. when she reaches the age of sixty. Her response to toxic exposures can change dramatically over her lifetime including when she is pregnant which also raises the issue of unborn children and their exposures. I have always shuddered at the prospect of a toxicologist in a lab somewhere determining a "safe" concentration for known manmade poisons that have no redeeming values. Yes medications are "safe" at the appropriate concentrations but can be poisonous if ingested above those levels. The point is that medications do have a redeeming social value. Dioxins do not! ........................................................................................................................... At one point in time I was advised that some chemicals have no threshold value. In other words there is no concentration low enough that ALL human beings will avoid negative health effects. This included dioxins. Various criteria, provincial and federal, acknowledge the toxicity of dioxins in comparison to other chemical compounds. For example we are advised that drinking water with less than 5 parts per billion (ppb) of benzene is supposedly "safe". Over 5 ppb. however can cause leukemia in human beings. Dioxins on the other hand have a criteria in drinking water of 15 parts per quadrillion. That is million, billion, trillion and then quadrillion. Each number is a thousand times larger than the preceding one and hence one part per quadrillion is 1,000 x 1,000 x 1,000 times SMALLER than one part in a million. You can see how much more toxic dioxin is than benzene, yet benzene is still a killer of human beings. .............................................................................................................. My conclusion is this. No concentrations of either benzene or dioxin should be in our drinking water. Or in our air. Or in our food. Then there are the thousands of other toxic chemicals used in industry and cheerfully discharged day in and day out into the natural environment. And yet industry and their professional shills blithly tell the public that this amount of chemical poison is safe and this amount is not. I believe that they are talking through their hats. Maybe the 44% of Canadians who will get cancer in their lifetimes feel the same way. I'm one of them although I think that I was very lucky. Many others are not. Yet we continue down this path of justifying and quantifying "safe" levels of toxins in our air, drinking water, ground water, surface water, soils and foods. Safe levels of toxins are a myth which allows some human beings to profit financially while exposing others to unecessary health risks.

FORMER ELECTROHOME SITE STILL CONTAMINATED - APARTMENT BUILDING PLANNED

We are talking about the decades long contaminated site at Duke and Shanley St. in Kitchener. The contamination is from a former owner dumping chemical solvents on the site. Both my expectation and recollection is that these solvents include DNAPLS or Dense Non Aqueous Phase Liquids. One example would be Trichloroethylene (TCE) which is the solvent that was either dumped or spilled by Northstar Aerospace in the Bishop St. community in Cambridge and which resuled in mass indoor air poisonings of residents there. ........................................................................................................................ We are advised in the article in today's Waterloo Region Record titled "8-storey apartment building planned for the former Electrohome site" that "The environmental contamination on the property is extensive...". That first of all is shameful. This is a residential neighbourhood in which both children and vulnerable adults have been living for decades. Secondly it tells me that most likely these dumped solvents are indeed DNAPL chemicals which include chlorinated solvents such as TCE. These DNAPLS will have been slowly dissolving into the groundwater for decades contaminating it. Do we really think that we have such a surplus of potable water that we can frivolously permit continued industrial destruction of our groundwater? I think not. Secondly TCE in particular can enter homes via soil vapour intrusion. This is exactly what happened in Cambridge and numerous other towns and cities across North America with lethal results including various cancers. ................................................................................................................... Our esteemed authorities, both municipal and provincial, have determined that it is cheaper to ignore soil and groundwater contamination even in residential areas than to proactively remediate it before residents and citizens suffer the health consequences. Afterall I expect that they and their children and families will be advised privately not to live in specific contaminated areas throughout Kitchener, Waterloo and Cambridge. Yet one more perk of being a politician.

WATERLOO REGION DISTRICT SCHOOL BOARD APOLOGIZES FOR THIRTY YEARS OF HARMFUL BEHAVIOUR

Well I didn't see this coming. I have long known that various senior staff at the WRDSB abused their positions and authority in a number of different ways. This particular issue was raised over the last couple of years after the Black Lives Matter movement began. Several local activists have taken both the Region of Waterloo and the local police to task over their alleged racist behaviour. Furthermore they made it clear that the regular Police presence in schools was not the benign, allegedly win-win scenario that it had long been depicted as. Certain racial minorities felt that they and their behaviour was being targeted or at least put under a microscope simply because of their race and they felt this was demeaning and disrespectful. .................................................................................................................... Today's Waterloo Region Record has an article written by Brent Davis which is titled "School Board apologizes for harms caused by policing program". In June 2020 the school board suspended the policing program and advised that how and when police were being used in schools was creating "...a sense of fear, increased anxiety and vulnerability for some, and especially Black, Indigenous and racialized students". The school board then voted last month to end the program entirely. Further they later issued the following statement on their website: "The fact that any student felt this way is not acceptable. We apologize, unreservedly, to the students and communities who have been harmed." .............................................................................................................................. Wow, I am impressed. Now I wonder if they have any interest in apologizing for their "Pass the Trash" policies, hopefully of the past, wherin bad teachers were not disciplined but simply transferred to different schools to be inflicted upon students and parents there. This unfortunately included child molesters as determined in the Ron Archer case which resulted in his doing jail time for his illegal activities both on and off school property.

This post originally was going to be about the $90 million that the Federal government have committed to a wellness/health centre to be built at Grassy Narrows for treatment of mercury victims. Victims of firstly Reed Paper and secondly of decades of both provincial and federal governments. Unfortunately the article that was in the Record's on-line version early this morning never made it to my hard copy paper delivered this morning. After going back to the on-line Record I find the article gone. This is not the first time this has occurred for whatever reason. ........................................................................................................... Reporter Paige Desmond wrote an article for the K-W Record titled "Chemtura boosts water cleanup" that was published on November 2, 2015. The article states that four new wells have been installed and infrastructure for treatment of the groundwater is also under construction. Jeff Merriman of Chemtura is quoted as saying that the company identified the need for additional work back in 2012 in order to achieve their 2028 mandated cleanup of the Elmira Aquifers. Of course Jeff "forgot" to mention that it was the citizens' committee CPAC who first identified the impending cleanup failure and went public with their findings. Both Chemtura and the Ministry of Environment denied CPAC's position for six months until they came up with their enhanced pump and treat plans. In the interim well W9 still isn't up and running and in fact pumping since 2015 (and 2012) only briefly exceeded the 2012 rates and in fact has been either the same or lower for most of the remaining years. The pump and treat system has been all about talk and not about actually pumping and treating more water. It's pretty clear that the new owners Lanxess Canada as well as the Ontario Ministry of Environment feel that they are in the end game and are trying their best to wind down the cleanup efforts. It's primarily been a public relations exercise for the past thirty-two years with lots of noise, talk, meetings, double dealings and little effective results.

THANK YOU ELZE BREDENKAMP

Going through old newspaper clippings mostly regarding Uniroyal Chemical I came across a Letter To The Editor in the Woolwich Observer from one Elze Bredenkamp. It was dated October 8, 2015. Now I'm not certain I know who that is but possibly she was the owner/proprietor of a small business on Church St. which is no longer there. Regardless her Letter To The Editor was critical of my right as a resident and voter in Woolwich Township, to take the mayor to task for her multiple irregularities in her post election Financial Statements. Now of course just as I and any other citizen have both a moral and legal right (Municipal Elections Act) to demand clarification of obvious failures in the mayor's Financial Statements, so does Ms. Bredenkamp have the right to object to my doing so. Unfortunately it appears that Ms. Bredenkamp probably hasn't even looked at the mayor's Financial Statements. I say that because there are exactly zero criticisms from her aimed at specific understating of expenses, improper corporate donations etc.. Ms. Bredenkamp's criticisms are entirely personal, aimed at me. For example she suggests that I'm looking for publicity and then she oddly turns around and calls me out by name in her Letter To The Editor. Perhaps the lady simply is a friend of the mayor and wanted to give her support. Fair enough but maybe the focus in your Letter should have been on the fine upstanding qualities of the mayor versus my alleged drawbacks. Anyhow carry on and perhaps in future research your facts a little bit better and you might better understand why some citizens object to taxpayer funded individuals breaking the law of the land as mayor Shantz did (i.e. Municpal Elections Act).

"EVERY DOG HAS HIS DAY"

Regarding that quote above I can state that I've had several of them in my life. Certainly the towering achievement for which I received credit and acclaim was my exposing of both Varnicolor Chemical in Elmira and the Ontario Ministry of Environment as complete fakes, charlatans and liars with no limits or concerns for the public interest. There have also been some glorious days regarding Uniroyal Chemical and their dishonesty over the decades. Pre-Internet times I had uncovered Brian Beatty's (Morrison & Beatty) nonsense regarding a DNAPL (Dense Non Aqueous Phase Liquid) report written by hydrogeologist Stan Feenstra. Back in May 2014 I discovered the Stroh Drain which has hounded Chemtura and Lanxess ever since. This of course was immediately after George Karlos of the Ontario Ministry of Environment solemnly, publicly announced to CPAC (Chemtura Public Advisory Committee) that he had personally walked the Chemtura property from the south-east corner over to the Stroh property and then southwards and he assurred CPAC that there was no possible pathway for contaminant travel from Uniroyal/Chemtura over to those properties (Stroh & Martin). A couple of either aerial or satellite photos had an odd curve from Chemtura over to the Stroh property that almost looked like the results of massive water flow. It turns out that both the flooding Canagagigue Creek and overflowing Uniroyal Chemical waste waters followed the same path. Who could have guessed? Also prior to May 2014 the Stroh Drain had always been left off, eradicated or removed from maps and photos with but one very old exception that I am aware of. ........................................................................................................... Of course these ah ah! moments have been interspersed with decades of falsehoods, blatant lies, coverups, denials and every form of deceit imaginable. Writing my book "The Elmira Water Woes: The Triumph Of Collusion, Deceit and Citizen Betrayal" was also a huge high for me. While it remains somewhat low key on-line (Waterloo Region Advocate) nevertheless it is there for both my and others to research and review the truth. So if there is one takeaway for polluters, their enablers and other professional liars it is this. Eventually the truth comes out and your behaviour, whether just nasty or criminal, will be exposed. Who knows maybe there is still a chance for this old dog to have his day yet again.

A LITTLE MORE ON THE JUNE 2021 PROGRESS REPORT

Table B.1 ...."Storm Water Outfalls-these used to be called MISA (Municipal Industrial Strategy for Abatement) outfalls. Regardless these are surface water drains from the Lanxess (Uniroyal) site that discharge into Canagagigue Creek. Following are the names of Uniroyal chemicals and their concentrations continuing to discharge into the creek to this day. ............................................................................................................ 2,4-D .........3.15 ppb....................................................................... Carboxin ......6.9 ppb....................................................................... Diphenylamine..3.06 ppb.............................................................................. Lindane ...... .11 ppb....................................................................... Toluene ...... .28 ppb....................................................................... ................................................................................................................ Table C.2 ...Comparison of upstream Canagagigue Creek water with downstream (below Uniroyal/Lanxess)...................... ................................................................................................................... Two chemicals are higher downstream than upstream and those are NDMA and Toluene. Neither are a surprise. .......................................................................................................................... However five chemicals have higher upstream concentrations than downstream and that should be a surprise.................. ........................................................................................................................... The five are m/p Cresol, 0-cresol, NMOR, TCE and xylenes. These speak to allegedly "unknown" upstream industrial sources. There isn't that much upstream from Uniroyal/Lanxess.

HOW MUCH WOOLWICH TOWNSHIP CORRUPTION REQUIRED PRIOR TO CRIMINAL CHARGES BEING LAID?

I read in today's Woolwich Observer that Boris Johnston's decision to reopen Britain early cost approximately 86,049 citizens their lives due to Covid infection. No charges are pending apparently. Looking at it that way I can see why to date no Woolwich Township (or Region of Waterloo) councillors have been criminally charged for their bad decisions. This includes the rezoning and proposed industrial development on the immediate east side of Lanxess Canada (formerly Uniroyal Chemical). This east side consists of mostly the Stroh farm but as well part of the Martin farm to the immediate south of the Stroh farm and south-east of Lanxess. ............................................................................................................................... Yes both properties are contaminated and repositories of Uniroyal Chemical toxins. That has been categorically proven with the Stroh farm with dioxins and DDT found in surficial soils on the Stroh farm close to the Lanxess property line. Also recent tests have indicated dioxins/furans and DDD in sediments of the Stroh Drain further south on the Stroh property. Using highly regarded (by polluters at least) scientific methods known as avoidance and denial, Lanxess and their partners in pollution have delayed for years any testing whatsoever of the Martin property and of the more likely highly contaminated parts of the Stroh property. While only testing sediments in two locations in the Stroh Drain, both came back with detections although the location further south, actually on the Martin property, had the highest concentrations. Indeed DP-1 (Drain Point 1) is just barely 20 metres to the west of the Martin swimming pond, long used by local Mennonite children. Of course we now have sediment testing both upstream and downstream of where some water from the Stroh Drain has been gravity flowing directly into the Martin swimming pond. .................................................................................................................... For those politicians with weak stomachs or consciences, no health testing to date has revealed health injuries in these children proven caused by Uniroyal Chemical's (Lanxess) dioxins or DDT and compounds (DDD, DDE). Oh right, I forgot. Our authorities have long refused health testing for Elmira and area residents directly impacted by Uniroyal Chemical's decades of toxic production including DDT, Agent Orange, NDMA etc.

LANXESS/GHD SAMPLE TESTING DEPTHS CONTINUE TO SUCK

Sediment sample depths from the bottom of creeks and drains are either 0-10 cm. (0-4 inches) or 10-30 cm. (4-12 inches). As a generality concentrations of some contaminants are greater with depth. This kind of tells you why the guilty parties ("powers to be") lie, bulls.it, bafflegab about shallow depths being better. What they mean is better for them and their interests ($$$). ........................................................................................................................... Soil samples from beside but above the normal waterline of creeks are taken at either 0-10 cm. (0-4 inches) or 10-30 cm. (4-12 inches). Again as a generality contaminant concentrations in soil increase with depth. There appears to be no consistency in regards to either sediment or soil samples regarding depth. In other words some samples are tested at both shallow depths (either 0-10 or 10-30) and others inexplicably are not. Or maybe it's not so inexplicable. Deeper samples generally have higher concentrations of contaminants and none of the guilty parties want that exposed if at all possible. .................................................................................................................................. Lanxess, GHD, MECP, Woolwich Township all seem quite capable of forgetting various soil samples found at depth on the Uniroyal/Lanxess property. I'm referring to real depth as in a number of feet deep not pretend "deep" samples from between four inches and twelve inches (i.e. 10-30 cm.). This includes during the excavations at GP-1 (2013-2014) as well as at test pits in and around (east) of RPE-5 after that. High concentrations of dioxins, PCBs were found eight feet below ground surface. ........................................................................................................................................ It's all about appearances. It's pretend science, pretend public consultation and even a pretend mayor who violated her conditional reinstatement to office by the Honourable Justice David Broad in July 2015.

STEP UP TIME FOR TAG

The Technical Advisory Group need to assess their mandate and their goals. This is not an easy thing to do as most of them, while well meaning and intelligent, have little or no historical involvement with Uniroyal Chemical, Lanxess Canada, Ontario Ministry of Environment (MECP), CRA or GHD. As my environmental colleague has pointed out, she knew long before I that the Chair of TAG (Tiffany Svensson) was not going to rock any boats. She definitely was not another Dr. Richard Jackson, whose departure was a huge loss for honesty and transparency in all things related to the 1989 Elmira Water Crisis. .................................................................................................................... Some TAG members have recently indicated that they were awaiting so called sediment sampling results from the bottom of the Stroh Drain before final comments on Lanxess/GHD and MECP refusal to test soils around the Stroh Drain, Ditch & Berm (SDDB). These soils especially need to be tested in the low lying area (bowl like) to the immediate east of the SDDB. Those sediment results are now back and perhaps TAG members are waiting for the next scheduled TAG meeting next month. Indeed Total TEQ or Toxic Equivalency is the measure of dioxins and furans in these sediments. While the ISQG or federal criteria is .85 parts per trillion (ppt), three of the four samples exceeded that criteria with one being at 24.4 ppt. This matter also relates to the issue of their fellow TAG member, Dr. Sebastian Seibel-Achenbach, and his appeal of November 2020 to them. Sebastian is insisting that he can not accept the refusal to test soils in the appropriate location by simple assertion of the company's client driven consultants that in their opinion, all is well and testing unnecessary. ......................................................................................................... TAG have smart and educated people on the committee. Only naivety or bias can prevent them from demanding these soil tests which could have and should have been done six or seven years ago. In fact the refusal then was followed by the attack on CPAC's integrity and credibility by both ignorant politicians and the other guilty parties in Elmira including the MECP. These soil tests need to be both shallow and deep not the usual 5.9 inches (15 cm.) deep and their location must be where experienced and highly knowledgable citizens have pointed out for years. This includes both a TAG member and very well informed local citizens denied both membership and a voice on TAG.

MAY & JUNE 2021 LANXESS PROGRESS REPORTS

So when did the alleged "pulse pumping" become almost no pumping? Prior to that advisory from Lanxess/GHD that they were going to be reducing groundwater pumping from well E7 it was a decades long mainstay of the off-site pumping regimen. Often the average daily pumping rate for the month was in the vicinity of 25 to 27 litres per second the highest pumping rate from any pumping well, off or on-site. Then we were advised that reducing groundwater NDMA concentrations around E7 (south end of Elmira) made full time pumping wasteful. Now the pumping is getting ridiculously low. June had a daily average of 13 litres per second and May, unbelieveably was down to 3.7 litres per second with I might add the Target Average still the same at 23.9 litres per second. Furthermore the footnote (1) for the Target Average column still states "GHD recommends that Lanxess maintain the target pumping rates gretaer than or equal to these rates." What the hell??? ................................................................................................................................... Seriously TAG and Tiffany you need to get this fixed yesterday. We still after more than two years do not have pumping well W9 up and running while E7 is also going down the toilet. In 2012 the public advisory committee (CPAC) were advised by Chemtura and Conestoga Rovers that they were going to TRIPLE the volume of off-site pumping. Well it's no longer even slightly higher (12-18%?) than those days as it was for some time and in fact for months now the off-site pumping rates are lower than they routinely were nine years ago. So who is the liar, Chemtura or lanxess or CRA versus GHD. Seriously TAG do your job (albeit volunteers) get on this!!!

"ENVIRONMENTAL CLEANUP" ON & OFF THE UNIROYAL SITE IS ALL A MINDGAME

I wondered initially what the purpose was of putting highly educated citiens in various environmental fields onto TAG. To me that seemed counterproductive to the goal of the Ontario Ministry of Environment (MECP) and Lanxess Canada which is simply to put the 1989 Elmira Crisis to bed and be done with it. Be done with public meetings, expensive monitoring and far more expensive remediation. Be done with even occasional media stories. Just to be clear no Woolwich Council do not have free rein to appoint whom they please to TAG although the Todd Cowan version of Woolwich Council tried. They were partly sucessful although Todd, ever the opportunist, looked frantically for some excuse to get me off the committee to please Chemtura after I'd already been appointed. What an ass.ole. ................................................................................................................... Now it seems that young, upcoming professionals are eager to please. They do not want to assume early in their careers that some (many) of their colleagues are corrupt. They do not want to believe that credentialed consultants routinely prostitute their opinions for the unholy dollar. If there is any doubt whatsoever than the wise consultant interprets facts and data in the most promising light of their client. At least if they want future work down the road from that client and maybe others. .................................................................................................................................... So the objectives are easy. Eliminate over time honest and sincere citizen activists by any and all methods. Elevate those that you can make private deals with that will not have to pass the test of public scrutiny and comment. Whenever necessary fudge soil, water, and sediment samples by using composite samples (i.e. average the high concentrations with others that you are confident are much lower). You can also fudge samples by using very high Method Detection Limits (MDL) as well as by ensuring that you take lots of samples in low or non-contaminated areas and as much as possible stay clear of sampling really problematic areas. Profess at all times, professionalism and a search for the truth in order to get either new or naive public consultation members on board. Lie to your advantage whenever you believe that you can either sell the lie or that evidence is lacking to prove the lie. ....................................................................................... In other words claim victory no matter how pathetic the failure and defeat are. Here in Elmira, Ontario, after lying to us for nearly thirty years, the guilty parties are now admitting that they can't restore the Elmira Aquifers to drinking water standards. They will sell that failure as a brilliant saving of electrical, money and other resources by diverting them away from forever pumping and treating the groundwater. They will also attempt to sell a pathetic Risk Assessment of the Canagagigue Creek. Among other reasons that it is pathetic is that the data from both the 2017 and 2020 investigations are marred by a plethora of Non-Detections based upon extravagently high Method Detection Limits which being far (sometimes) in excess of the criteria return Non-Detections. ..................................................................................................................... The complete refusal of MECP and Lanxess to sample soils in and around the Stroh Drain I believe proves that they are in bed together and corrupt. They are saving each other, time, money and face. TAG are holding back on their final comments on that refusal to sample soils until they formally see the sediment samples recently released (> than criteria for dioxins). That should do it but never underestinmate the lying, politics and manoevering of corporate polluters.

WATERLOO REGION RECORD PUBLISHES UPDATE ON PROPOSED SHANTZ STATION (Maryhill) GRAVEL PIT

First of all despite the title above let me advise readers that yesterday's Woolwich Observer also published an article about the proposed pit as well as their Editorial was titled "Pitting what's democratic against what get's approved". It too was excellent. .............................................................................................................................. Leah Gerber's article in the Record today was titled "Maryhill gravel pit decision deferred until early August". The sub -title is "Neighbours say mine too close to businesses, homes, could impact water, health". Woolwich Council decided to defer their decision until August 10/21. I was pleased to see in Leah's article (as well as the Observer's), the number of councillors who clearly are uncomfortable with the location of the proposed pit despite Woolwich staff advising that Capitol Paving have jumped through all the approriate hoops and loops (read technical reports) and are in compliance with all relevant legislation. There is the rub. The province are pro aggregate and the public be damned. Same thing with the Ministry of Natural Resources and Forestry. Hence the legislation merely gives the public the opportunity to disagree. In fact they have very little substantive legally upon which to hang their arguments. They are good arguments. In a nutshell the gravel pit will lessen the neighbour's enjoyment of their properties as well as damage roads and put traffic, both pedestrian and vehicular at greater risk. A nearby school will also be negatively affected. ...................................................................................................................................... Above and beyond the sloped versus level playing field in this disagreement is the fact that aggregate need isn't even on the table. In fact it is specifically legislated off the table. Opponents cannot demand that information and proponents do not have to even respond to those questions. So why are aggregate companies continuing to expand their supply of gravel pits, often within a mile or two of each other when their is no shortage of gravel? Some suggest it is to lower the costs of transporting their gravel to its' end use and hence each aggregate company can increase their market share by being able to provide their product closer to construction sites, cement and asphalt plants etc. ............................................................................................................................................. So will Woolwich Council stand up on their hind legs and say no to Capitol Paving who to this date have everybody else, including Woolwich planning staff, behind them? Or will Woolwich Council in order to avoid appeal costs that they would likely lose, roll over and capitulate? Or will some sort of semi face saving compromise be found? Could Capitol Paving toss Woolwich Council a bone that they could crow about to the citizens and businesses in Maryhill when Council approves the applications from Capitol Paving?

ANY OTHER METHODS TO INSIST THAT MECP & LANXESS FOLLOW ENVIRONMENTAL LAWS?

Laws that are unenforced are essentially useless. This certainly includes environmental laws. Also laws written with huge loopholes are essentially useless. Finally laws that depend upon voluntary compliance are beyond shameful. In this case here in Elmira, voluntary compliance has been converted into the polluter being in complete charge of the cleanup, from initial Phase 1 investigations to major input into Control Orders as well as all monitoring, work plans, investigations and finally remediation. The system is built so as to give the polluter control over much of the expenses he is going to face over the decades in the case of a major mess, such as Elmira, Ontario. There is one other fly in the ointment. Just as Russia is alleged to have compromising information on former President Trump, so to does the polluter here have compromising information on the Ontario Ministry of the Environment. ....................................................................................................... How could they possibly not? The Ministry or its' predecessor, the Ontario Water Resources Commission (OWRC), made concessions and deals with Uniroyal Chemical that were not in the public interest. Either formally or informally permitting unlined in ground waste pits, ponds and lagoons to operate for decades with the toxins being produced by Uniroyal was way beyond negligence or ignorance. Sure the company suggests that their "historical" waste practices were the norme. Or they were the best available practices at the time. Hog rot to that. Early chemical manufacturers in Germany and Switzerland had learned their lessons the hard way in the late 1800s (1860-1890). There were actually sucessful lawsuits launched against those companies prior to 1900 which forced them to stop the practice. Granted some of them then simply discharged directly into the Rhine and Rhone Rivers until that too was stopped and chemical liquid waste treatment became mandatory. All of this was half a century prior to the explosion of North American chemical manufacturing with both governments and industry pretending that the wide open spaces of Canada and the U.S. could readily dilute, diminish and naturally attenuate toxic liquid wastes. It didn't work in Europe and it sure as hell has not worked here. The reality is that chemical manufacturers simply found a less stringent jurisdiction in which to inflict their own waste treatment costs upon the general population. ............................................................................................................ So what is left for citizens? Well Greenpeace and other environmental organizations have certainly focused attention upon environmental disasters such as Grassy Narrows (mercury) and many others. David Suzuki took quite an interest in Elmira in the very early days (1990-1993) and produced an excellent Documentary. Local media also did a fabulous job in the early years between the Elmira Independent, K-W Record, CKCO-TV and local radio. It is however all old news now with some minor exceptions. I was advised decades ago that APT seemed unenthusiastic about longer term interest and engagement by outside environmental groups. At the time I assumed (wrongly) or was told that it was better for a local group to be in charge of opposing Uniroyal Chemical than some outside group. Maybe it's time to see if one of the bigger groups would like a second kick at the can because at the moment it's looking very bad. Lanxes/GHD/MOE/MECP are running the show and running it very badly. Pathetic, bullsh.t, psudo scientific reports rule the day (still) and the "cleanup" of the Elmira Aquifers by 2028 is an admitted failure. All that's left is the disappointment awaiting Elmira and downstream residents when the multiple guilty parties finally determine how little cleanup of the Canagagigue Creek that they can get away with. Rest easy however, they'll have "experts" galore on board with whatever they want to do.

DRAWING OUTSIDE THE LINES IS O.K. IF YOU WEREN'T ALLOWED TO HELP DRAW THOSE LINES IN THE FIRST PLACE

I heard and or saw an ad recently for a law firm advertising their services to appeal Workman's Compensation Board (WCB) decisions. I can not recall if the ad was on TV, on-line, newspaper or wherever. The point the ad raised was that appealing any such adverse decision using the process provided by either the Ministry of Labour or the WCB was a waste of time. The law firm made it clear that internal appeals to the same body who made the original decision and was totally in charge of the appeal process was simply window dressing. Therefore the law firm was advising legal action through the courts to redress the initial adverse decision. Now if only some of our courts themselves were less biased and less cognizant of the status, power and money before them. .............................................................................................................................. Undoubtedly our authorities who have tied up the entire investigation and remediation process at contaminated sites will howl like banshees in outrage if any stakeholders turned their back on them and their so called "public consulation" and so called "Qualified Persons" bullsh.t. They don't mind so much if stakeholders including local residents, either short term or long term involved, walk away in disgust. What would greatly offend them is any attempt to bring in a third party form of either mediation or even legal action. There is absolutely no way not to get your way when you and the other parties have all made your private deals. Then even if one guilty party is under pressure to do more you can remind them of all that they have to lose if they don't play ball and or forget who brought them to the dance in the first place. ..................................................................................................................................... Our legal system has long been grossly biased in favour of the very well off. Idiots like Trump for example have turned the courts into a playground for the rich to harass the less rich. Unless you can afford a full time lawyer to deal with unexpected (or expected) court dates, filing dates, etc. then you end up jumping through hoops and loops literally for years as the financially better off party introduce Motions for this and for that, at least partially designed to keep you busy and stressed. It is a contemptible process and is not remotely user friendly by design. It is however Judge and lawyer friendly and as a collegue of mine has stated it is the "Just Us" system not the justice system. ........................................................................................................................................... Is there a better way? Undoubtedly but any attempts at long overdue reform will be met with great opposition.

JUNK SCIENCE & CONFUSION EQUALS SUCCESS FOR LANXESS & GHD

The title above is my Conclusions and Summary of the "2020 Canagagigue Creek Sediment and Soil Investigation" report produced by GHD on behalf of Lanxess Canada and dated June 30, 2021. This is somewhat in contradiction to GHD's Concclusions and Summary on pages 24 and 25 of the text. GHD claim that their Figures 6.12, 6.13, 6.14 and 6.15 show concentrations of both soil and sediment data from both the 2017 sampling/investigation as well as from this most recent one namely 2020. These Figures allegedly show these concentrations relevant to distance from the Grand River and each Figure represents one of the four contaminants namely DDT, DDE, DDD and TEQ (dioxin) concentrations. I have to say that they are pretty Figures as in pretty useless and irrelevant. The text admits that "Non-detect data was not considered within the data analysis." In other words the majority of the data which was absolutely useless due to high Method Detection Limits leading to the majority of the data being Non-Detect, was ignored. All that was left were the detected compounds whether soil, sediment, DDT, DDE, DDD or dioxins/furans which was a function not so much of their actual concentrations present as much as a function of the size of what appeared to be arbitrary, illogical and unreasonable Method Detection Limits (MDL) used. To say that MDLs for the same parameter and in the same medium (soil or sediment) bounced around like a ping pong ball in a tornado is an understatement. ...................................................................................................................... Keep in mind that the 2017 Canagagigue Creek Investigation was also a pile of pus in scientific quality due to both bizarre MDLs as well as bizarre sediment sampling procedures namely the shovel method versus proper, formal core samplers. ................................................................................................................................ Page 25 Section 6.7 of the text then informs us that Figures 6.16 to 6.19 compares the soil and sediment data by parameter with each other versus distance from the Grand River. So already biased data will be compared within itself (soils versus sediment) to allegedly represent what: the extent of contamination in these two different mediums at different distances from the Grand River. This is nothing but more and deeper (you know what) and is also a clear example of GIGO - Garbage In = Garbage Out. Apparently GHD asked for and received from their client an exemption to this well known data processing law that says that you can't put bad data into a computer and expect it after computations to then produce good data. Hence GIGO! GHD then solemnly advise readers that "GHD recommends that the data set be evaluated under a Human Health and Ecolgical Risk Assessment framework." In other words again quoting GHD (pg. 25-26) "In order to fully understand and evaluate the data represented by this sampling program and determine appropriate next steps, a better understanding of the associated risks to human health and the environment are required.". Soooooooo I'm going to name this process GIGO-GIGO-GIGO. What this means is that Garbage In producing Garbage Out (2017 Creek Investigation) combined with more GIGO (2020 Creek Investigation) then combined with more GIGO yet (self- managed & controlled by the polluter Risk Assesssment) will produce a satisfactory (to Lanxess/GHD/MECP) result allowing a minimum of cleanup while providing the veneer of science, truth, data and logic to which all guilty parties can hide behind. TAG and RAC plus local citizens will all be victims yet again of the three B's namely Bullshit Baffles Brains.

THE MOST EGREGIOUS EXCEEDANCES OF CRITERIA BY METHOD DETECTION LIMITS (MDL): 50 - 200 TIMES HIGHER !

I've finally finished the report. Unlike certain alleged experts, professionals and others I actually read everything and then go back and analyse that which I've read. Over the last few days I've been posting some of my findings here. Simply put there are more Non-Detect results, whether Soils or Sediments, than there are detections. Hence there are also more Non-detects than there are exceedances of criteria. If we were sampling clean farmland that would be expected. We are not however. In fact the vast majority of MDLs that are listed are far in excess of the criteria assigned to the specific chemical tested for in the sample, again whether Soil or Sediment. Regarding diffent parameters (chemicals) being tested for, four of the five of them have MDLs far in excess of their criteria, whether provincial (Table 8) or federal (ISQG). This refers to Lindane, DDD, DDE, and DDT. For whatever reason all the samples tested for dioxins/furans (i.e. Total TEQ) had Method Detection Limits (MDLs) below the criteria of 7 parts per trillion (ppt). Also keep in mind that the criteria for TEQ (Toxic Equivalency) is measured in ppt which are literally a million times smaller than the measurement of parts per million (ppm) being used for Lindane and the various DDT compounds. Eg. ppm are 1,000 times larger than ppb (parts per billion) which are a thousand times higher than ppt. ............................................................................................................................. Soils have MDLs that exceed their criteria at lower rates/multiples than do sediments. Partly this is do to the lower criteria for sediments and partly due to lower soil MDLs in some locations. For example the exception is Reach 2 in the creek which actually has much lower soil MDLs than does Reach 4. This of course creates a sampling bias which favours greater positive detection in the much further downstream Reach 2 than in Reach 4. However that is strongly counterbalanced by the fact that Reach 4 includes the Uniroyal/Lanxess property which is the ultimate source of these contaminants in the first place and has more and higher deposits of contaminants in both soils and creek sediments. There is no legitimate comparison, in my opinion, between all the various locations and sample parameters because of this ongoing apples to oranges nonsense. This is not science so much as, I believe, a deliberate attempt to confuse. GHD and Lanxess do not want citizens or the general public to be able to read and understand what their version of science is. I suggest that their version as indicated in both this report (2020 Canagagigue Creek Soil and sediment Investigation) and the 2017 Canagagigue Creek Investigation is at best junk science and at worst fraudulent science. ............................................................................................................... Soil MDLs exceeding their criteria do so between 1.6 and 10 times. That of course seriously inhibits finding all the exceedances of criteria for Lindane, DDD, DDE and DDT. Sediment MDLs however exceeding their criteria do so between 3.1 and 244.7 times with numerous exceedances (12) well in excess of 100 times the criteria. This makes getting positive detections of contaminants very difficult even in highly contaminated sediments. I assume that that is the intent of the authors. If they have some legitimate rationale for these ridiculously high MDLs then they need to 1) explain them 2) explain how ridiculously inaccurate and generally useless the results are which purport to indicate certain areas of the Creek requiring attention and hopefully cleanup.

POLITICAL ACCOUNTABILITY: PERHAPS LINK JAIL TIME WITH LENGTH OF TIME TOXIC CHEMICALS HAVE BEEN IN CANAGAGIGUE CREEK

I think on a basis of one year in jail for every ten years that the creek has been contaminated with toxic substances from Uniroyal Chemical in Elmira would be very generous and compassionate. Not of course for the victims of incompetence, negligence and self-serving behaviours but for the perpetrators that is. The real debate should be not so much how long in jail as much as who gets to go and experience our judicial/correctional systems first hand. Certainly provincial politicians who have been part of the governing party should be eligible unless you believe that just Cabinet ministers have any power and authority. O.K. then, each and every Ontario Cabinet minister since say the late 1950s would be good. Then of course how about the mandarins leading the Ontario Ministry of Environemnet and its predecessor, the Ontario Water Resources Commission. So lets say the Regional Directors for the West central region again since say the late 1950s. Finally of course I think that each and every corporate ownership involved since the 1940s should join the jail procession. I mean all the successor com[panies from Crompton, Chemtura and Lanxess have purchased the site with full knowledge of what they bought and how serious the contamination is and to date none of them have done much cleanup while talking up a storm. They've talked and had reports written while those living along the creek have continued to suffer. ............................................................................................................................... Now of course we would certainly see what kind of "independent" judiciary we have for this to happen. Afterall what government in power is going to pass new legislation criminalizing their past colleagues? Nope the judical system is going to have to go after these criminals using the currently available laws that prohibit criminal negligence causing bodily harm as well as other laws prohibitng intentional physical harm of human beings. Pat Potter would have referred to the exercise as the "Uniroyal Trials".

ZERO LINDANE DETECTIONS IN SOIL VERSUS ZERO DIOXIN NON-DETECTIONS IN SOIL

That is zero soil detections of lindane either near the four background creeks and the Stroh Drain as well as the three Reaches (2, 3, & 4) of the Canagagigue Creek. That seems odd for a prior determined Contaminant of Concern (COC). The joys of high Method Detection Limits (MDL). Conversely dioxins/furans (TEQ) had both zero soil and sediment (bottom of the waterway) NON-detections in all samples! Wow - the joy of reasonable MDLs. ........................................................................................................................ There was a grand total of ONE lindane detection in this entire report which was in sediment in the Bolender Park creek. I presume that is the tiny creek running the lenght of the north side of the Park, former landfill and car wrecking yard. The creek then turns 90 degrees south and runs parallel to Arthur St. before discharging into the Canagagigue Creek. The concentration of lindane in sediment was .022 parts per million (ppm) which exceeds the criteria (.00094 ppm) by about twenty-five times. Keep in mind that lindane is but one of Uniroyal Chemical's signature chemicals and that Uniroyal happily dumped into the Bolender Park Landfill despite all attempts to minimize that uncomfortable fact by Woolwich township and others over the decades. ............................................................................................................ I will emphasize again that high Method Detection Limits grossly distort the number of contaminant detections as well as the number of contaminant exceedances of criteria. If in some instances they are unavoidable then report writers should not blandly lump in a plethora of ND (non detects) and treat them as legitimate non-detects when in fact what they actually are, are non-measurable samples. Readers literally have no idea in many cases if the contaminant is present or not and if it is whether it's above or below the health criteria set by various governments. ............................................................................................................ Further examination of this "2020 Canagagigue Creek Sediment and Soil Investigation" will focus on both the extent and size of MDL's exceedances of criteria and on how many of these high MDL non-detects there are in relation to actual relevant, useable, good data.

INTENTIONAL CANAGAGIGUE CREEK SAMPLING BIASES REDUCE LANXESS CLEANUP COSTS

Liars can figure and Figures can lie is a very old truism. Then there is the one possibly from Winston Churchill that states: Lies, damned lies and statistics. You get the picture. Numbers and figures have been the go to method for unscrupulous, self-serving folks to get their way for time immemorial. Politicians especially love them because most are too lazy and too dumb to actually carefully analyse the numbers themselves. Hence they can cheerfully ask for a "summary" from their toadies and underlings to support whatever their position is. ................................................................................................................ The soil and sediment investigation of the Canagagigue Creek in 2017 was riddled with various errors, typos and subterfuges. The most recent one titled "2020 Canagagigue Creek Sediment and Soil Investigation" dated June 30, 2021 is just as bad. A major part of the scam is to judiciously use varying Method Detection Limits (MDL) to ensure fewer detections of toxic compounds in and around the Canagagigue Creek. Inappropriate MDLs can also focus attention in one direction and away from areas that you'd rather readers not notice. Particularly areas that could cost you more time, more money and more public scrutiny and or condemnation. ................................................................................................................................... The simplest and most obvious criticism is that the MDLs are repeatedly and constantly higher than the provincial or federal criteria for most of the contaminants of concern (COC). This means that if for example the criteria (provincial-Table 8) for Total DDD in soils is .05 parts per million (ppm) and as is typical in this report you have a MDL of either .11 or .23 ppm then with the first MDL (.11) your sample of DDD needs to be actually more than double the criteria in order for the lab to detect it. If the MDL is .23 as it often is in this report then your sample concentration would have to be almost five times higher than the provincial health criteria to be detected by the lab. In other words by having laboratory detection limits (MDLs) in excess of the government mandated health criteria you are artificially reducing the number of both low level detections of the contaminant as well as detections sometimes well in exceedance of the criteria. Also realize that these MDLs can be to a certain extent an intentional request of the person submitting the samples (polluter or his consultants). For example it may be that the lab charge less for analyses with higher MDLs than with much lower MDLs. This is due to the greater effort and care required by the lab for lower MDLs. Also realize that all of these legally mandated criteria, no matter how low, are achievable by the proper accredited labs. This ability to achieve lab analyses is of course required before any pollution standards/concentrations are set in the first place. ...................................................................................................................................... There is yet another possible reason for a high Method Detection Limit (MDL). It is sometimes referred to as matrix interference and refers to the situation where a lab is analysing a sample for a particular contaminant but that sample is also contaminated with a very high concentraion of other different contaminants. This sometimes can force the lab to be unable to achieve the MDL that they would like. Likely in the case of Uniroyal/Crompton/Chemtura /Lanxess this has occurred to their advantage. In these cases it is grossly misrepresentative to the point of fraudulent, in my opinion, for the report writers not to CLEARLY & REPEATEDLY advise the readers throughout the text if the high MDLs (greater than criteria) are caused by matrix interference and high concentrations of other contaminants. Also it is highly misrepresentative, as this report does, to repeatedly suggest that sampling has shown that numerous contaminants such as Total DDD, DDE and DDT are non-detect within a sample when in fact that non-detection is simply an artifice of the ridiculously high MDLs. ................................................................................................................... Generally speaking the MDLs are lower both for soils and sediments further from the Lanxess property (i.e. further downstream in the creek). This induces greater detections further downstream and reduces detections closer to their plant. Also the high MDLs are more biased against sediment detections than soils because the sediment criteria are so much lower than the soil criteria. Therefore greater numbers of detections and possible exceedances in the sediments are not determined as they are referred to as Non-Detect. I have also noticed in the Background samples for four different creeks that there appears to be a bias against both Shirt Factory Creek detections and Landfill Creek detections. In other words MDLs are actually lower for the same chemicals in Bolender Park Creek and in the unnamed creek (Larch's Creek?). Finally there is a huge bias with the MDLs towards getting detections of dioxin/furans versus getting detections (and exceedances) for DDD, DDE, DDT and Lindane. Apparently there is very little problem in achieving very much lower MDLs for dioxins (it has a much lower criteria) than there is for the much higher criteria and MDL DDT compounds. If there is some honest rationale for this it badly needs to be explained versus the appearance that DDT compounds are few and far between while dioxins are evrywhere. ............................................................................................................................ I am still examining this report carefully. As a general comment I will however state the following. What a deal it is for polluters if they can both save money upfront with lower per unit lab analysis costs (due to higher MDLs) and then also save money at the back end with lower cleanup costs due to fewer detections of toxic compounds. God bless our democratic, free enterprise system.

K-W RECORD ADVISES THAT "MENNONITES COULD BE AT RISK FROM CREEK"

Please! "...could be at risk...". That would be funny if it weren't so pathetic. Generations of Old Order Mennonites living along the creek have been seriously impacted by chemicals they've inhaled, ingested and even with skin contact with soils and sediments in the bottom of the Canagagigue Creek. The local polluter variously named Uniroyal Chemical, Crompton, Chemtura and now Lanxess Canada have been fully supported by all levels of government in avoiding the appropriate consequences of their intentional and knowing negligence causing disease and death to their neighbours. It has taken fifty to over a hundred years for the negligence and neglect that caused the loss of young lives in residential schools to cause an outcry and outrage from the public. Lanxess and friends, especially political ones, will eventually get their just rewards. ................................................................................................................................ Today's article by Leah Gerber serves the public interest. It advises which chemicals currently are still present despite the stoppage of on-site dumping fifty years ago. The problem chemicals are appropriately known as Persistent Organic Pollutants (POPs) and include dioxins/furans and DDT. Yes these do bioaccumulate and have longterm health effects on both humans and wildlife. Unfortunately however what the article does not tell the public is that the process is completely under the control of all the guilty parties. They are going through the motions to pretend to be "fixing" things. In fact since day one (November 1989) of the Elmira Water Crisis it's been all about minimizing the truth and the facts of the severity and extent of contamination and most importantly minimizing the cleanup costs to the polluter. ........................................................................................................................ The Old Order Mennonites along the creek have been sufferring the ill effects from pollution since the very late 1940s. With the ending of on-site toxic waste disposal around 1970, the more obvious, visble and odourous effects have been lessened. Then in 1997 hydraulic containment of Uniroyal's south-west creekbank also significantly lessened groundwater discharge of chlorophenols, solvents and other noxious liquid wastes into the creek. In one sense those improvements may have led to greater exposures as the downstream residents noticed that the creek looked and smelled better not knowing that the POPs had not been removed and indeed would not be removed for decades longer if at all. ....................................................................................................................................... This "cleanup" has been a sham from the beginning. A few co-opted and self-serving citizens combined with the majority of self-serving politicians have allowed, in my opinion, these corporations to get away with murder. Shame on them all.

LIARS LIE & DECEIVERS DECEIVE

YOU the readers can decide for yourselves. Following are some quotes from the "2020 Canagagigue Creek Sediment and Soil Investigation Report" by GHD dated June 30, 2021. "DDT and metabolyte results were all less than Table 8 Standards ..." (Pg. 14 6.1.1). That is a bald faced lie! Due to the high Method Detecion Limits (MDL) such as .11, .17, and .23 ug/g it is impossible to know whether the Shirt Factory Creek soil samples do or do not exceed the MECP Table 8 standards of .05 ug/g for Total DDD and DDE or .078 for DDT. ................................................................................................................................. "Lindane was not detected above the sample reporting limits and reporting limits were all less than the Table 8 Standard."(Pg. 15 6.1.3) Another bald faced lie! The Table 8 Standard for Lindane is .01 ug/g. In fact most of the reporting limits (i.e. MDL) were exactly the same as that standard/criteria. However the MDL or reporting limits for Lindane samples at Shirt Factory Creek were much higher namely .060 ug/g which is six times higher than the Table 8 Standard of .01 ug/g. ................................................................................................................ "Results for DDT and its metabolites were all less than their associated ISQG criteria." (Pg. 15 6.1.4) Bald faced one again! In fact the MDLs (Method Detection Limits) ranged from .034-.23 ug/g while the criteria for DDD is .00354, for DDE is .00142 and for Total DDT is .00119 ug/g. O.K. I've just spotted a footnote that suggests that GHD may have multiplied these lab result concentrations by "...the fraction of organic carbon in each sample." Hunh! So now the question is whether the federal sediment criteria are indeed as they are publicly stated/published and are GHD doing this mathematical multiplication in order to reduce the concentrations below the published federal criteria? Or as the footnote indicates is this multiplication by the fraction of organic carbon solely to calculate SELs (Severe Effect Levels) and not for ISQG (Interim Sediment Quality Guidelines)? Interestingly here in the text I see no results for this. Well luckily for GHD/Lanxess/MECP I personally and the public in general are refused the right to publicly ask the filthy polluters these questions. It might hurt their wee feelings. .......................................................................................................... "All remaining Lindane results were less than the ISQG and SEL criteria." (Pg. 16 6.1.6) Well again we have a criteria of .00094 ug/g with MDLs ranging from 0.010-.10 ug/g. That's going to require some mighty tricky stickhandling to pretend that MDLs that are ten to one hundred times higher than the sediment criteria for Lindane can give any kind of accurate or meaningfull numbers. The calculation for multiplying the alleged fraction of organic carbon by the cdoncentration found by the lab does not seem to be here in the text. Elsewhere perhaps, less likely to be found/read? .................................................................................................... Finally there is yet another possibilty. Is this stuff about fractions of organic carbon legitimate in any universe other than that of GHD? It would have been appropriate for them to supply some kind of technical opinion on the matter by unbiased, nuetral experts. I've seen CRA in the past come up with some weird technical claims. Is this just the same old, same old self-serving nonsense to bail out their clients? If so where are the Ontario MECP and why aren't they stepping in and calling a foul???

HAVE THE REGION OF WATERLOO BEEN GILDING THE LILY REGARDING THE GRAND RIVER?

A week ago today there was an article in the Waterloo Region Record titled "Pollution makes the Grand River "sick" written by J.P Antonacci. It described the journey by boat down the Grand River by a group of both native and non-native Canadians. The natives decided to see what the effects of development, both industrial and residential were on the health of the river. It was an eye opener. North of Kitchener-Waterloo including Elora and Fergus tyhe water was clean and clear. Going south through the most heavily built up and densely populated sections of the riverthe paddlers noticed the effects of pollution, soil erosion and agricultural runoff. They could tell by both the colour and the odour of the water. ................................................................................................................................. Currently the Haudenosaunee Confederacy (native Canadians) have a moratorium on development within the Haldimand Tract which extends approximately six miles on each side of the Grand River. They are looking for consultation with builders and governments. Our courts at the moment may be reluctant to honour that moratorium although there have been some signs of movement on the matter of development without consultation. Regarding the pollution, the paddlers noticed a direct relationship between the amount of development and the deteriorating water quality. They specicially mentioned the crystal clear water in Elora versus how dark the water is in Kitchener, Waterloo and Cambridge. One student from Western University on the trip mentioned that growing up in Brantford, she and her friends knew how gross the water in the Grand River was. ............................................................................................................................... If there was an optimistic note it was that seeing how much cleaner the river was in the northern parts they felt that there was hope eventually for the river further south, with good stewardship. My opinion is that the combination of ever increasing development and population combined with flowery tributes, good intentions and governments gilding the lily all essentially doom the Grand River to continue deteriorating in water quality. Here in Waterloo Region legacy projects like the Light Rail Transit trump and outweigh spending on Sewage Treatment Plants and better planning and development decisions along the river.

SCIENCE OR MOSTLY GAMESMANSHIP?

So Thursday morning I discovered that a 700 plus page report had been sent me by e-mail (yet again). It is titled the "2020 Canagagigue Creek Sediment and Soil Investigation". Last fall additional soil and sediment sampling was undertaken to allegedly fill in data gaps etc. from the inadequate 2017 Canagagigue Creek Soil and sediment Report. In my opinion, and as expressed here, the 2017 report was inadequate for a plethora of reasons. My recollection includes amateurish and error ridldled Tables, text and more. It includes Method Detection Limits possibly for hundreds of samples that were far in excess of the provincial or federal criteria that the concentrations of various contaminants were being compared to. As a direct result there were likely hundreds of results that were pure and simple garbage. In other words flatly stating that there are no exceedances of criteria for DDT or dioxins/furans for example that are saddled with Method Detection Limits (MDLs) that are dozens to hundreds of times higher than the health based criteria is simply, in my opinion, fraudulent. It is an intentional attempt to minimize a horrible environmental situation that calls out for extensive and expensive remediation. Lastly the actual method of sampling for sediments in the bottom of the creek was a farce. Instead of consistently using a proper core sampler to get a consistent sample of sediments at the bottom of the creek, they repeatedly used a shovel that of course lost most of its sediments as it was lifted through the water to the surface. The excuse was that the bottom of the creek was "armoured" with coarse gravel, stone etc. .......................................................................................................... Enough of a stink was raised over the shovel methos versus core sampling that adjustments were made for this report. Essentially locations for sediment sampling were transferred away from sections of the bottom of the creek that were armoured. Geez rocket science it isn't but hopefully it works better and gives good data versus the last stupid attempts. Much of what was sampled was long overdue although while I haven't completed reading the report it once again looks like way too little sampling and way too much gamesmanship. Background sampling has been ignored for a very long time. Uniroyal Chemical managed to screw up the environment both on and off their own property. They mangaed to dispose of toxic wastes in areas that they never should have. This included formal municipal landfills and if rumours are accurate on private property around Elmira for a price. What we do know is that both Uniroyal and Varnicolor Chemical used and abused dumping priveleges at a host of different landfills in Waterloo Region including several in and around Elmira. ............................................................................................................................... This latest report has similar problems with far too many samples being tested at unrealistic, basically ridiculously high MDLs that completely negate any possibility of knowing whether the sample actually has DDT or dioxin in it. Of course Lanxess's consultants GHD, interpret every Mickey Mouse Non-Detect result with high MDls as evidence of a lack of their client's contaminants being present in the sample. How convenient and how self-serving. This is where the old saying about the fox being in charge of the hen house came from. It is an unimaginable conflict of interest and in an honest, democratic and reasonable society this report and its authors would be thrown out the door and told never to return. Not in Elmira however. .......................................................................................................................... All the four background samples plus the new sampling in Reaches 4,3, and 2 of the Canagagigue Creek included soils and sediments. Not however in the Background area to the creek composed of the Stroh farm. There after seven years we have only had two locations (4 samples) sampled in the bottom of the Stroh Drain for sediments. The results were in excess of the federal sediment quality guidelines. They were also high when compared with most of the rest of the other sediment results in this report. Further examination is required but to date it is clear that DDT and metabolytes are being grossly minimized with high MDLs. Dioxins not nearly as much. Lindane is also being disadvantaged by the use of ridiculously high Method Detection Limits which essentially indicate that the laboratory can not measure low enough to even come close to the calculated and MEASURABLE criteria that have been determined by our governments to protect us and wildlife. I shall continue reading this outrage.

MORE OPPORTUNITIES FOR THE PROFESSIONAL LIARS TO EARN THEIR MONEY IN ELMIRA

Spin doctors, politicians, lawyers, consultants, co-optees, polluters and regulators will be doing their thing with the latest report released by the polluter and his consultants GHD. The report released Wednesday evening, immediately before Canada Day, is more of the same nonsense, bullshit, deception and deceit as long practiced here in Elmira by so many. It is titled "2020 Canagagigue Creek Sediment and Soil Investigation" dated June 30/21. Is the report useless from end to end? Of course not. There are some honest soil and sediment samplings I'm sure mixed in with all the deceptive and deceitful data presented as being scientifically valid. Just as with the 2017 Canagagigue Creek investigation there are far too many Non-Detect (ND) samples that are in fact no such thing. What they should be called are either Non-Samples or Non-Existent Samples. This is because the Method Detection Limits (MDL) are so much higher than either the environmental or human health criteria which are used to determine the risk or toxicity levels of various contaminants. ................................................................................................................................... One example is the seven year old wait for soil samples in and around (east side preferably) the northern couple of hundred metres of the Stroh Drain. Still no soil samples as both the Ontario MECP and Lanxess have finally in writing (Minutes of April TAG meeting) confirmed that they view the Stroh farm as having been remediated. What a pathetic joke. However for the first time we have four sediment samples taken from the bottom of the Stroh Drain (cutely referred to as 6770 Line #86). Three of the four have dioxin (Total TEQ) levels well in excess of the Interim Sediment Quality Guidelines (ISQG). Also three of the four samples have alleged Non-Detects for Total DDD and four of the four Lindane, Total DDE, Total DDT samples are all Non-Detect. It is of course a mathematical artifact/construct of intellectual prostitutes who are O.K. with facts as long as they are presenting them in the light that they prefer. This of course includes exclusion of informed, experienced local citizens who are not "friends" of Lanxes, MOE/MECP or Woolwich Council such that they can not speak at TAG (citizen members) to these matters. ................................................................................................................... These alleged Non-Detects for Lindane, DDE and DDT with only one detect out of four samples for DDD is courtesy of Method Detection Limits (MDLs) sometimes as high as one to three hundred times higher than the criteria. Think of it this way. By abusing the MDLs and including Non-Detects that really are no such thing you can for example show half a dozen detections for toxic contaminants but have fifty or more alleged Non-Detects (with high MDLs) thus suggesting to ill informed readers that most ares of the creek are "clean". Again what a pathetic joke! Liars and deceivers start your engines!